Carbajal v. Government Service Insurance System
REITERATIONFacts
The Antecedents: Nenita P. Carbajal, employed as Campaign Clerk in the Municipal Treasurer's Office of San Julian, Eastern Samar, suffered from bleeding per vaginum due to incomplete abortion while performing her duties. She was hospitalized and treated but eventually died on March 8, 1976, from profuse hemorrhage secondary to complete abortion and shock. Procedural History: Petitioner filed a claim for benefits under P.D. No. 626 with the Government Service Insurance System (GSIS). The GSIS denied the claim, stating the ailments were not occupational. Upon reconsideration, the GSIS reiterated its denial, asserting no causal relation between the ailment and the work conditions. Petitioner appealed to the Employees Compensation Commission (ECC), which affirmed the GSIS decision, finding no proof of compensability or increased risk due to working conditions. The Petition: Petitioner sought review of the ECC's decision, arguing that the nature and conditions of his wife's employment aggravated or increased the risk of her illness.
Issue(s)
Whether the illness of the deceased, Nenita P. Carbajal, resulting in her death, is a compensable sickness under Presidential Decree No. 626, as amended, and whether the risk of contracting the ailment was increased by the working conditions attendant to her employment.
Ruling
The petition is GRANTED. The decision of the respondent Employees Compensation Commission is SET ASIDE, and respondents are ordered to pay the petitioner the full amount of compensation under Presidential Decree No. 626, as amended.
Ratio Decidendi
On the compensability of the illness and increased risk due to working conditions: The Court found the petitioner's contention meritorious. Under Article 167(I) of the Labor Code, as amended by P.D. No. 626, a sickness is compensable if it is an occupational disease or if the employee proves that the risk of contracting it is increased by the working conditions. The records showed that the deceased suffered "two attacks of vaginal bleeding and hypogastric pain" while working, which she attributed to lifting heavy tax declaration books, leading to incomplete abortion. Medical authorities indicate that pregnant women should avoid occupations involving heavy lifting or strenuous exertion, as such activities can cause injurious reactions and may result in spontaneous abortion due to overexertion. The opinion of the ECC Medical Officer that there was no causal relation was overcome by the substantial evidence submitted by the petitioner, including medical certificates and affidavits confirming the connection between her illness and her work. The Court emphasized that medical opinion to the contrary can be disregarded, especially when there is some basis in the facts for inferring a work connection, citing previous rulings. Furthermore, the Court reiterated the principle that all doubts in the implementation and interpretation of the Labor Code shall be resolved in favor of labor, consistent with the State's policy of giving maximum aid and protection to labor. This liberal interpretation is in line with the social justice mandate of the Constitution.
Main Doctrine
The risk of contracting an illness is considered increased by working conditions if there is substantial evidence to infer a work connection, even if medical opinion to the contrary exists, and doubts in interpretation shall be resolved in favor of labor.